Global Trustee and Fiduciary Services Bite Sized Issue 8 2025

6 QUICK LINKS CBDC CRYPTOASSETS CSDR EMIR FINTECH FSB OPEN FINANCE OPERATIONAL RESILIENCE SUSTAINABLE FINANCE/ESG ASIA PACIFIC NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 8 | 2025 These pillars would be supported by three critical enablers: • Technology infrastructure; • Consumer trust; and • Industry collaboration. In addition to the findings of the Open Finance Sprint, the FCA states that it will launch the Smart Data Accelerator to aid the development and implementation of open finance and smart data sharing in the UK. In addition, the FCA says it is working with the UK government to set out an open finance roadmap by March 2026. Link to Report here OPERATIONAL RESILIENCE ESAs Publish Guide on DORA Oversight Activities On 15 July 2025, the European Supervisory Authorities (EBA, EIOPA, ESMA – the ESAs) published a guide on the oversight of critical third-party providers (CTPPs) under the Digital Operational Resilience Act (DORA). Under DORA the ESAs are responsible for the pan-European oversight of CTPPs enhancing the overall digital operational resilience across the various Union financial areas. This oversight framework helps to address potential systemic and concentration risks arising from the financial sector’s reliance on a limited number of ICT providers. It complements, rather than replaces, financial entities’ own responsibilities for managing ICT-related risks and the supervision already exercised over them by competent authorities (CA). The aim of the guide is to provide an overview of the processes used by the ESAs, through the Joint Examination Teams (JET), to oversee critical Information and communication technology (ICT) third party service providers. The guide provides high-level explanations to external stakeholders regarding the CTPP Oversight framework. Furthermore, it provides an overview of the governance structure, the oversight processes, the founding principles, the tools available to the overseers, and the adoption process. The ESAs state that it is intentionally written to facilitate understanding of the regulatory framework and its practical application. It does not substitute the legal acts, which should be consulted in the Official Journal of the EU for the full text of the relevant provisions. The guide may be revised and reissued over time as oversight experience continues to develop. Link to Guide here SUSTAINABLE FINANCE/ESG The SBTi Opens Net-zero Standard for Finance Industry On 22 July 2025, the Science Based Targets Initiative (the SBTi) released the Financial Institutions Net-Zero Standard (the Standard) which, the SBTi says, “provides clear, actionable science- based guidance for banks, asset owners and managers, private equity firms and other financial institutions to align their lending, investment, insurance, and capital markets activities with limiting global warming and achieving net-zero by 2050 at the latest.” By setting targets against the Standard, the SBTi said financial institutions “can set a clear route to build resilience, meet evolving stakeholder expectations, manage climate-related risks, and capitalise on emerging opportunities.” The Standard is aligned with the SBTi’s Corporate Net-Zero Standard, as well as other relevant sector-specific standards and guidance, supporting integration into existing risk and investment processes.